Privacy Notice - Lakeview

Online Privacy Notice

Lakeview Loan Servicing, LLC (“Lakeview” or “Company) recognizes the importance of keeping the personal information you provide to us private and secure. Lakeview has developed a comprehensive privacy policy and we use the latest technology to ensure that your personal information is secure. Lakeview respects your privacy and is committed to providing a transparent notice of our Privacy Notice and Disclosure for California Residents. This Privacy Notice and Disclosure for California Residents applies solely to those who reside in the State of California (“consumers” or “you”). The purpose of this privacy notice and disclosure is to inform California residents, at or before the time of collection of personal information and to inform you as part of our privacy policies.

Lakeview reserves the right to change this policy at any time.

Information We May Collect

Lakeview may collect certain types of information from you, such as information you voluntarily provide via forms, surveys, applications, etc. when you visit the Company’s sites. We may also collect information about you from your online browsing and transactions, including your preferences, pages visited, technical information regarding your computer and operating systems, such as your Internet Protocol (IP) address, domain name and system configuration and settings.

Links

At certain places on this site, live “links” to other Internet addresses can be accessed (“Linked Sites”). Such Linked Sites contain information created, published, maintained, or otherwise posted by institutions or organizations independent of Lakeview does not endorse, approve, certify or control these Linked Sites and does not guarantee the accuracy, completeness, efficacy, timeliness or correct sequencing of information that they contain. Lakeview’s Privacy Policy does not apply to these Linked Sites. The privacy policies of these Linked Sites may differ from Lakeview’s, and you should review their policies before accessing them and/or submitting information. Lakeview is not responsible for the privacy or security of these sites, including the accuracy, completeness, reliability or suitability of their information. If you are asked to provide information on one of these websites, you are strongly urged to carefully study their privacy policies before sharing your information.

Cookies

Cookies are pieces of information stored directly on the computer you are using. The Company, or any of the Company’s third-party advertising service providers, may place cookies or similar files on your hard drive for security purposes, to facilitate site navigation and to personalize your experience while visiting the Company’s sites. Cookies allow the Company’s to collect technical and navigational information, such as browser type, time spent on its respective site and pages visited. Cookies allow the Company to select which of its advertisements or offers are most likely to appeal to you and display them while you are on the Company’s websites. The Company may also use cookies in online advertising to track consumer responses to the Company’s advertisements and may use cookies or other files to track your use of other websites. Cookies and other technologies provide the Company the capability to monitor the use of the Company’s websites so the Companies can continually improve the design and functionality to better serve you. Cookies and similar files do not contain or capture unencrypted personally identifiable data.

If you do not accept these cookies, you may experience some inconvenience in your use of some online options. You also may not receive advertising or other offers from the Company that are relevant to your interests and needs. The Company uses web-browsing cookies to display information more effectively to you and to gather data about the usage of the Company’s websites.

At times, Lakeview may use other technologies to capture customer specific data to help understand how customers use its sites and to assist us with resolving customers’ questions regarding the use of our online sites.

Advertising

Lakeview advertises on pages within its websites as well as on other websites not affiliated with the Company. The Company may contract with another organization to advertise to you through the use of cookies, social media platforms and web beacons.

Information collected through cookies, social media platforms and web beacons includes the number of people who look at each of the pages on the Company’s websites, social media platforms, search engine referrals, browsing patterns within the Company’s websites, and responses to advertisements and promotions on social media platform or the Company’s websites. Information collected may also include other trends and activity on the Company’s websites, social media platforms, and basic information about whether you have visited the sites before, your Internet connection and computer settings, such as your browser, your IP address and your time zone.

From time to time, consumers will experience ‘Pop Ups’ from other companies while visiting the Company’s sites. Pop Ups are generated by ‘Adware’ placed on your computer when other sites have been visited. Lakeview does not participate in the use of Adware.

Advertising on the Company’s Websites

The Companies advertise their respective products and services, on pages within the Company’s websites. These advertisements may take the form of banner ad, and other applicable formats.

Advertising on other Websites or Social Media platforms

Lakeview contracts advertising with other companies to advertise the Company’s information and services on websites not affiliated with Lakeview. If you click on one of the Lakeview ads, you link to the particular Company website that offers the advertised service. These ads may contain cookies that allow tracking of your response to the Company’s advertisements. These cookies do not identify you personally. Lakeview prohibits any company that places Lakeview ads from using this information for any purpose other than to assist us in measuring the effectiveness of the Lakeview ads.

How the Companies use and share information

Unless otherwise described in this policy, Lakeview will use and share any information that the Company collect from or about you that is covered by this policy in accordance with this Privacy Policy.

The Company may also share aggregated or anonymous data about the Company’s customers and visitors to the Company’s websites with advertising service providers and with companies that help Lakeview understand how you use its websites.

Looking out for children

Lakeview does not knowingly market to or solicit information from children under 13 without parental consent. Lakeview recognizes that protecting children’s identities and privacy online is important, and that the responsibility to do so rests with both the online industry and with parents. While the Company works to protect your personal information, you also have responsibility.

Internet safety for children. The Internet is a public network. Children’s access to the Internet can allow them to visit inappropriate websites and be exposed to unwanted risks. COPPA, the Children’s Online Privacy Protection Act, protects children under the age of 13 from the online collection of personal information. Learn more about COPPA on the Federal Trade Commission’s website. Parents can be proactive by installing filtering software that gives them more control over their family’s Internet experience.

Lakeview recommends that minors 13 years of age or older ask their parents for permission before sending any information about themselves to anyone over the Internet.

Security

We maintain commercially reasonable security measures to protect the personal information we collect and store from loss, misuse, destruction, or unauthorized access. Our security includes physical, administrative, and technology-based measures. We use industry-standard encryption to protect data in transit and at rest. Our internal policies and procedures impose a number of standards to safeguard the confidentiality of personal information, prohibit the unlawful disclosure of personal information, and limit access to personal information. While we undertake these security measures, you acknowledge that no security measure or modality of data transmission over the Internet can be guaranteed to be 100% secure. We take security seriously; however, you should not expect that any personal information provided to us through the Site is free from the risk posed by unauthorized access.

Your Internet session is encrypted if your security-enabled browser is connected to a web site using the Secure Hypertext Transport Protocol. URL strings beginning with “HTTPS://” instead of the usual “HTTP://” indicate that the secure protocol is in effect. Your browser may also tell you if security is operating. For example, Netscape Navigator may display the icon in the lower left corner of your screen in secure mode. If 128-bit security is in effect, it shows the icon. Microsoft Internet Explorer shows an icon in either case. Note that security may be operating without any visible indication if the web page you are viewing employs frames (see below). If secure transmission is not in effect or only part of a frame-based page is secure, Netscape shows the “broken key” icon, and Explorer does not show the “lock” icon.

CALIFORNIA PRIVACY RIGHTS NOTICE

Additional Notice for California Residents

At Lakeview, we are mindful of our responsibilities under the California Consumer Protection Act (“CCPA”) (Cal. Civ. Code § 1798.100 et seq.) regarding the collection, use, and disclosure of your personal information, both online and offline. This online notice applies only to California residents who are subject to the CCPA.

Most visitors of our website are either representatives of businesses seeking to interact with us as part of their jobs, or individuals engaging with us in connection with using our financial products or services. Please note that personal information we obtain, use, or is disclosed through these business-to-business interactions or pursuant to the Gramm-Leach-Bliley Act (“GLBA”), or the California Financial Information Privacy Act (“CFIPA”) are exempt from the CCPA.

How We Collect, Use, and Share Personal Information

Personal Information of California Residents Collected in the Last Twelve Months

We collect information that identifies, relates to, describes, references, and is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). In particular, we have obtained the following categories of Personal Information on California residents within the last twelve months:

Identifiers such as real name, alias, postal address, email address, IP address, unique personal identifier, online identifier, account name, social security number, and driver’s license number, passport number or other government issued number, when you submit this information to create an account, apply for a loan, request to learn more about our financial products and services, or subscribe to email alerts.

Any information that identifies, relates to, describes, or is capable of being associated with a particular consumer or household, including, the “identifiers” listed in (A), and the following: signature, insurance policy number, employment, employment history, bank account number, credit card number, debit card number, or any other financial information when you apply for or receive a loan which was then provided to us when we became your master servicer.

The following categories of protected classification characteristics under California or federal law: date of birth/age (40 years or older), gender, race, color, national origin, citizenship, or marital status, when you provide it to us.

Internet or other similar network activity information, including, but not limited to, browsing history on our websites, search history, and information on your interaction with our websites or applications when you choose to visit and interact with our websites or applications.

Audio information such as recordings of when you called into our customer contact line; visual images from security cameras in our branch offices; and electronic information in the form of Internet or other electronic network activity information, as described above.

Current or past professional or employment-related information, including job history, performance evaluations, position details, or references.

For each of the above categories, most of the Personal Information we have obtained was provided by you as part of your mortgage origination process, which was then provided to us when we became your mortgage servicer, or information we received from third parties in connection with processing, underwriting, funding, and servicing your loan. This information is necessary for us to complete your mortgage loan transaction or transact as a mortgage servicer in accordance with federal and state law.

We use commercially reasonable security measures to protect the information we have obtained, in accordance with federal and state regulations. Please visit our Privacy Policy for more information about the security measures to maintain information.

Please note that Personal Information does not include:

Publicly available information from government records
De-identified or aggregated consumer information; and
Information exempted from the CCPA’s scope, including without limitation, the GLBA, the Fair Credit Reporting Act (FCRA), California Financial Information Privacy Act (CFIPA), the Driver’s Privacy Protection Act of 1994, and certain information associated with business-to-business transactions.

Our Use of Personal Information for Business Purposes in the Last Twelve Months

We use the Personal Information we obtain, identified in each of the above categories, for the business purposes listed below.

Audits and reporting relating to particular transactions and interactions, including online interactions, you may have with us or others on our behalf
Detecting and protecting against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecuting the same
Debugging to identify and repair errors in our systems;
Providing services on our behalf or on behalf of another, including maintaining or servicing accounts, providing customer service, fulfilling transactions, verifying identity information, processing payments, and other services;
Conducting internal research to develop and demonstrate technology;
Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which we may own, control, or provide;
Preparing statistics and performing analysis to support our operations;
Conducting surveys regarding our products, services, and client satisfaction; and
Receiving and responding to inquiries.

Our Sharing of Personal Information in the Last Twelve Months

Disclosures of Personal Information for Business Purposes

Lakeview does not share any information about you or your company to unaffiliated third parties, except as necessary to process, underwrite, fund and service your loan and as permitted by law. Within the last twelve months, we have disclosed Personal Information identified in the Categories A-F above only (i) at your express request; (ii) as part of an exempt business-to-business commercial transaction; (iii) in connection with providing you a financial service or product for personal, family, or household, pursuant to the GLBA; or (iv) to our service providers for the business purpose(s) described above.

When we disclose Personal Information for a business purpose, we execute a contract that describes the purpose and requires the recipient to keep Personal Information confidential and not use it for any purpose except performing the contract.

No Sales of Personal Information

We do not sell Personal Information within the meaning of the CCPA nor do we plan to sell Personal Information. If that changes, we will let you know in advance and provide you with information so that you may understand and exercise your right to opt-out of the future sale of your Personal Information.

Please note that we do not collect, use, sell or disclose Personal Information of individuals we know to be under the age of 18 to business partners or third parties.

Privacy Rights and Choices for California Residents

If you are a California resident, the CCPA provides you with certain rights related to your Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

As discussed above, the CCPA does not apply to all or nearly all information we obtain, use, or share as part of our role as a financial institution or resulting from certain business-to-business transactions. We will, however, continue to evaluate our business-to-business activities throughout 2021 and update our Privacy Policy consistent with California laws and regulations, where applicable.

Access to Personal Information and Data Portability

You have the right to know what Personal Information we have obtained and disclosed about you for a business purpose in the last twelve months. Once we receive and confirm your verifiable consumer request, we will disclose to you any or all of the following:

The categories of Personal Information we collected about you;
The categories of sources from which the Personal Information was collected;
Our business or commercial purpose for collecting that Personal Information;
The categories of third parties with whom we share that Personal Information;
The specific pieces of Personal Information we collected about you (or portability request); and
If we disclosed your Personal Information for a business purpose, a disclosure identifying the categories of Personal Information that each category of recipient obtained.
We are not required to comply with a verifiable consumer request for access or data portability twice within a 12-month period.

Deletion Request

You have the right to request that we delete (and direct our service providers to delete) Personal Information we collected about you and retained, subject to certain exceptions.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

complete the transaction for which we collected the Personal Information,
provide a good or service that you requested,
take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
debug products to identify and repair errors that impair existing intended functionality;
exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
comply with the California Electronic Communications Privacy Act;
engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement,
if you previously provided informed consent;
enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
comply with a legal obligation; or
make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Opt-out of Sale of Personal Information

The CCPA provides you with the right to direct us to not sell your Personal Information. However, as discussed above, we do not engage in the sale of Personal Information as contemplated by the CCPA.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. This means that we may not deny you goods or services, charge you different prices or rates for services or provide you with a different level or quality of services (or suggest that we will do so), in response to a request made under the CCPA.

We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your Personal Information.

Exercising Your CCPA Rights

To exercise one or more of the above rights, you or someone you authorize, may submit a request by:

Writing us at Lakeview. Compliance Department, 4425 Ponce De Leon Boulevard, 5th Floor, Coral Gables, FL 33146 or email at privacy@lakeview.com. Reminder: please include the statement “Attention: California Privacy Rights Request” in the subject line of your email or within the body of your written request, as well as your name, email address, phone number, property address, and your account number. We may limit our response to your exercise of the above rights as permitted under applicable law. We will review each request carefully and respond accordingly within the timeframe established by the CCPA.

However, as discussed above, the CCPA does not apply to all or nearly all information we obtain, use, or share as part of our role as a financial institution or through certain business-to-business transactions, and we will not include any of that information in responding to your request.

Please note that we are not responsible for notices that are not labelled or sent properly, or that do not have complete information. If applicable, we will provide you with information on how to submit the request or remedy any deficiencies with the request. Responses to your CCPA request will be delivered in the same manner that we received it.

Verifiable Request

As required under applicable law, we take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. You must provide us with enough information to allow us to reasonably verify you are the person about whom we collected Personal Information, or an authorized representative, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. Please include the statement “Attention: California Privacy Rights Request” in the body of your written request, as well as your name, email address, phone number, property address, and Community account number. We may limit our response to your exercise of the above rights as permitted under applicable law. We will review each request carefully and respond accordingly within the timeframe established by the CCPA.

Agent Authorization and Disability Access

You may designate an authorized agent to make a CCPA request for personal information on your behalf. To designate an authorized agent to act on your behalf, you must provide the agent with written permission to do so and provide proof of your identity. Written permission may include a power of attorney sufficient under California Probate Code §§ 4121 to 4130.

You may also make a verifiable consumer request on behalf of your minor child, but you must also provide proof that you are that child’s parent or legal guardian.

Other California Privacy Rights

California “Shine the Light” Law (Civil Code Section § 1798.83)
Under the Shine the Light Law, a California resident may ask us to refrain from sharing your Personal Information with third parties for their direct marketing purposes. Please know that we do not share Personal Information of California residents with third parties for their marketing purposes.

California Do Not Track Disclosure

Our website and applications are not designed to respond to “Do Not Track” requests from browsers.

Contact Information Regarding this California Notice

You may contact us with questions or concerns about our privacy policies or practices and your choices and rights under California law by writing us at Lakeview. Compliance Department, 4425 Ponce De Leon Boulevard, 5th Floor, Coral Gables, FL 33146 or email at privacy@lakeview.com. Reminder: please include the statement “Attention: California Privacy Rights Request” in the body of your written request, as well as your name, email address, phone number, property address, and your account number. Again, we may limit our response to your exercise of the above rights as permitted under applicable law. We will review each request carefully and respond accordingly within the timeframe established by the CCPA.